This section contains the verification requirements for all MO HealthNet and adult cash assistance programs.
The Eligibility Specialist, as an employee of the Family Support Division, has the responsibility of requesting necessary verification and recording information in the case record that clearly documents all eligibility requirements for a program are met, or that one or more requirements are not met and ineligibility exists.
Individuals applying for or receiving assistance have the responsibility to provide information or access to the information needed for determining eligibility, both initially and on a continuing basis.
NOTE: If the applicant signs a release form for the FSD to have access to the information needed for determining eligibility, but the source will not provide the information requested to the FSD, requires payment for the response, or requires a company specific form, inform the applicant/participant that they must obtain the information from the source directly. It is the applicant/participant's, authorized representative's, and/or legal representative's responsibility to provide the FSD with all information regarding the eligibility unit's income and circumstances at the time of the initial application and ongoing to determine eligibility. It is the Eligibility Specialist's responsibility to inform the applicant/participant what information is needed. Ensure the Request for Information (FA-325 or IM-31A) form clearly identifies the documentation that must be provided.
An applicant must be given at least ten days to supply necessary information per request. A MO HealthNet for Aged, Blind, and Disabled (MHABD) application may be rejected after two Request for Information (FA-325 or IM-31A) forms. When the first written request expires a second Request for Information (FA-325) form is automatically generated by FAMIS, allowing an additional 10 days to return requested information. The second FA325, shown as request "Two", can be viewed or printed from the Document Queue (DOCQUE/FMVM) screen. If FAMIS fails to generate the second request, the Eligibility Specialist should do so, following the User Guide instructions for Editing and Adding Text to the FA325.
NOTE: If an MHABD MO HealthNet application is rejected prior to the actual due date of the application for failure to provide verification or failure to cooperate, and then all of the requested information is received on or prior to the due date of the application, the application should be cancel rejected and processed using the original date without requiring that the applicant submit a new application document.
For active cases, if the participant refuses or fails to provide the necessary information to establish continuing eligibility within ten days, authorize an adverse action to close in FAMIS, or send a Adverse Action Notice (IM-80) form to close.
Note: A collateral contact is not required prior to approval of any MO HealthNet application. If information provided by the applicant is questionable, it may be helpful to contact a collateral to clarify the household's situation. Do not routinely contact a collateral prior to approving MO HealthNet applications.
Questionable Documentation or Other Verification
The agency is not required to accept questionable documentation or other questionable verification. If the applicant/participant, authorized representative, or legal representative provides documentation or other verification that appears to be inaccurate, incomplete, inconsistent, inauthentic, or not true, send a Request for Information form (FA-325 or IM-31A) to the applicant/participant and/or their legal guardian, conservator, or authorized representative requesting the clarifying or additional information needed. Allow ten days for the applicant/participant, legal guardian, conservator, or authorized representative to provide the information needed to determine eligibility.
If the requested information is not received or does not resolve the discrepancy, authorize the rejection or adverse action to close the case for failure to cooperate.
Record comments from the Eligibility Unit Member Role (EUMEMROL/FM3Z) screen or hard copy of case file for cases not in FAMIS. Comments must provide a detailed explanation of the documentation received and the reasons that the documentation or other verification appears to be inaccurate, incomplete, inconsistent, inauthentic, or not true.
NOTE: If the Eligibility Specialist learns of information effecting the eligibility determination, which was not disclosed at the time of the original application and was not a change in circumstances, allow the applicant/participant, authorized representative, or legal representative up to the application due date to provide needed verification. If the necessary information needed to determine eligibility is not received by the due date, authorize the rejection for failure to cooperate. Do not exceed the application processing time frames. See Application Processing section 0105.045.00 DELAYS IN PROCESSING IM APPLICATIONS.
Any case action can be challenged in a hearing so there must be a rational, reasonable explanation for taking action, such as closing or rejecting a case, based on the information provided or not provided. Staff must be able to explain, based on logic and facts, not on conjecture, prejudice, or emotion, why the documentation was questionable and the application was denied.
Accept the applicant's statement, unless questionable.
Verification of age and relationship of a child to their parent/caretaker should be obtained by viewing IBTH for all applicants/recipients born in Missouri. It is appropriate to accept the applicant's statement, unless questionable, for anyone born outside Missouri.
For programs that require a person to be of a certain age (over 18, over 21, under 21, over 65, under 65, etc.) accept the claimant's statement unless questionable. Verification of the Social Security number by the system is acceptable verification of age. If age is a critical factor of eligibility for a program and the claimant's statement is questionable further documentation must be obtained. Documents of almost any kind which state the age of the claimant at a given date may be accepted as verification, provided they appear to be authentic.
This requirement applies only to those persons for whom healthcare coverage or cash assistance is being requested or received. It does not apply to parents, children or a spouse included in the assistance group for whom coverage has not been requested.
Obtain a copy of the Social Security card for all persons for whom coverage is requested at the time of the initial application whenever possible. If a card is not available but the number is known, accept the applicant's statement and enter the Social Security number into the SUPD system. If the number is correct, it will be verified by the system. It is only necessary to obtain further verification if the system match returns an indicator other than “V”.
For persons requesting coverage who do not have a SSN, proof of application for the SSN must be obtained prior to the individual's approval. If the IBTH screen indicates a SSN was requested, further verification is not required.
Do not deny or delay approval pending issuance of an SSN once the application for the SSN has been completed.
Section 6036 of the Deficit Reduction Act of 2005 amended section 1903 of the Social Security Act effective July 1, 2006 to require states to obtain satisfactory documentation of citizenship and identity prior to approving Medicaid benefits. Individuals receiving Medicaid benefits in July 2006 were required to provide verification of citizenship and identity at the next reinvestigation.
Section 211 of the Children’s Health Insurance Program Reauthorization Act (CHIPRA) signed February 4, 2009, amended section 1903(x) of the Social Security Act. The law allows an individual declaring to be a citizen or national of the United States who is required to present documentary evidence of citizenship or nationality a reasonable opportunity to present the documentation. A reasonable opportunity is defined as 90 days from the date of approval.
Per 42 CFR 435.407 presentation of evidence documentation for citizenship and identity is a onetime activity. Once a person’s citizenship and identity has been verified and recorded in any Family Support Division – Income Maintenance database subsequent changes in eligibility should not require repeating the documentation unless later evidence raises a question of the person’s citizenship.
Documentation must be maintained in the case record and as allowed by 42 CFR 435.407 may be copies of documents, unless the copy is questionable. The copy may be submitted in person, via fax, scan or other readily acceptable electronic formats.
The following individuals are exempt from having to provide documentation of citizenship/identity:
Acceptable forms of documentation that verify both citizenship and identity are:
If one of the above forms is not available, you must obtain one of the following documents to verify citizenship and a second source to verify identity:
Acceptable forms of documentation that verify identity include:
For children under age 16, identity can be verified by the signature of a parent/related caretaker/legal guardian on the application or reinvestigation forms. This signature is considered an affidavit to the child’s identity.
NOTE: Do not request verification of identity again when the child turns 16 years old as long as there is continuous eligibility for that child and there is the prior affidavit signature of the parent/related caretaker/legal guardian.
For all other individuals, including children applying as their own caretaker, the following documents can be used to verify identity:
If the individual is unable to obtain documentation listed above for either citizenship or identity, contact the Income Maintenance Program and Policy Unit for further assistance.
To enter non-citizenship information in FAMIS, complete the following steps.
If verification is not provided, leave the document type and verification fields blank. FAMIS pends the application until proper documentation is provided and entered. The applicant’s statement that he or she is a U.S. non-citizen National is sufficient for interim eligibility. Enter CS (client statement) if verification is not provided. At the next certification, remove the CS code and verify the status.
When an application for MO HealthNet is received without documentation of citizenship, provide the applicant with a Request for Information (IM-31A or FA325) for the necessary documentation. Once verification of all other eligibility factors is received, approve the eligible applicant and set a priority or reminder to follow up with the participant in 90 days. If documentation of citizenship or national status is not provided within 90 days and the participant is not making a reasonable effort to provide the documentation, action must be taken to remove the participant from MO HealthNet coverage.
NOTE: Documentation of citizenship includes proof of identity. Therefore, the application may be approved pending documentation of citizenship even when proof of identity has not been provided.
When approving an applicant that meets all other eligibility factors other than documentation of citizenship, take the following actions:
If documentation has not been provided within 90 days, provide the participant an IM-31A allowing 10 days to provide verification. If the participant fails to respond within 10 days:
If the participant responds, but does not have citizenship documentation:
EXAMPLE: Ms. Williams, age 49, did not have documentation of citizenship with her when she applied for MO HealthNet for the Aged, Blind, and Disabled (MHABD) on 7-15-09. The eligibility specialist provided Ms. Williams a Request for Information asking for documentation. On 8-10-09, the Medical Review Team determined Ms. Williams is permanently and totally disabled. Ms. Williams now meets all eligibility requirements for MHABD except for documentation of citizenship. The eligibility specialist approves her application and enters "P" in field 13H1 of IMU5. A priority is set in field 18 to follow up on citizenship documentation in November.
Ms. Williams fails to provide documentation of citizenship by November. The eligibility specialist sends Ms. Williams a Request for Information to provide documentation of citizenship within 10 days. Ms. Williams fails to respond within 10 days. The eligibility specialist sends Ms. Williams an Adverse Action Notice (IM-80) to close her MHABD case. After no response, the eligibility specialist takes action to close Ms. Williams' case when the Adverse Action Notice (IM-80) expires.
EXAMPLE: Although Mrs. Portico, age 58, had a certified copy of her birth certificate from the State of Indiana when she applied for MHABD on 7-27-09, she did not have proof of identity, which is a part of citizenship documentation. The birth certificate is in Mrs. Portico's maiden name of Williams, and her current driver's license is in her married name of Portico. The eligibility specialist provided Mrs. Portico a Request for Information asking for documentation needed for identity. On 9-22-09, the Medical Review Team determined Mrs. Portico is permanently and totally disabled. Mrs. Portico now meets all other eligibility requirements, and her application is approved. The eligibility specialist enters "P" in field 13H1 of IMU5. A priority is set in field 18 to follow up on citizenship documentation in December.
In December, Mrs. Portico is not able to provide the documentation of citizenship, but provides the eligibility specialist proof that she has contacted the county clerk's office in the county where she was married to obtain a copy of her marriage license. The eligibility specialist sets a priority to follow up in March.
When completing the controlled flow for an applicant that meets all eligibility requirements other than documentation of citizenship, take the following actions:
If verification of citizenship and id has not been received, the ES will complete the entry of the code CTV-Citizenship Verification Not Provided on the Eligibility Unit Member Role (FM3Z/CITVERF) screen and an eligibility determination (EDRES) is completed to remove the participant from the active case. A FAMIS User Guide titled “Removing an Individual from MO HealthNet for Failing to Provide Citizenship Verification” has been added to the intranet with the steps to complete the action.
If the participant is making a good faith effort to provide documentation, take the following actions:
EXAMPLE: Ms. Terry applied for MO HealthNet for Families (MHF) on 7-20-09. Ms. Terry meets all eligibility requirements for MHF except for documentation of citizenship. The eligibility specialist enters "PEND" in the Citizen Document field and leaves the "Ver" field on the Citizenship Verification (FM8X) screen blank. When the controlled flow is completed, the TECH result for citizenship shows pending, and there is an outstanding verification for documentation of citizenship. The ES creates a Request for Verification (FA-325) and enters “Please provide documentation of citizenship and id. If citizenship and id documentation is not provided within 90 days, MO HealthNet benefits will be closed for all individuals who have not provided the documentation” in the text field. Then the eligibility specialist fastpaths to the Citizenship Verification (FM8X or CITVERF) screen, enters a "CS" in the "Ver" field, and completes an eligibility determination (EDRES). Ms. Terry passes on citizenship. The eligibility specialist approves Ms. Terry’s MHF application and sets a reminder for 90 days to follow up on citizenship documentation.
Ms. Terry fails to provide documentation of citizenship within 90 days. The ES completes the entry of the code CTV-Citizenship Verification Not Provided on the Eligibility Unit Member Role (FM3Z/CITVERF) screen and an eligibility determination (EDRES) is completed to remove the participant from the active case.
An individual can reapply for MO HealthNet Program (MHN) after being closed for not providing verification. However, the application cannot be approved unless verification of citizenship is provided. If verification of citizenship is not provided within the normal application processing timeframes, the application is rejected at the end of the application period. The individual is not allowed an additional 90 days to provide verification of citizenship when the individual has previously been allowed 90 days to provide documentation.
When an individual who has previously been allowed 90 days to provide requested verification of citizenship reapplies for benefits, the Eligibility Specialist should enter "PEND" in the Citizenship Document field and leave the verification field blank on the Citizenship Verification screen (FM8X or CITVERF) in FAMIS. If citizenship documentation is not provided by the end of the application period, the system automatically rejects the application for failure to provide documentation of citizenship.
Example: On 07/23/2010, Ms. Smith applies for MO HealthNet for Families (MHF) for herself and her three children. Ms. Smith does not have citizenship documentation for herself or her three children. Ms. Smith is given a Request for Information (FA-325) notice requesting citizenship documentation, the case is approved, and a reminder is set to follow up 90 days from the date of approval. Ms. Smith fails to provide documentation within 90 days. The eligibility specialist removes the "CS" verification code in the "VER" field on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS and a FA-325 Request for Information is sent to Ms. Smith requesting verification of citizenship. Ms. Smith fails to provide the requested information and does not contact the eligibility specialist (ES) claiming a good faith effort in obtaining the citizenship verification. FAMIS sends an Adverse Action Notice (FA 410). When the Adverse Action Notice (FA 410) expires, the MO HealthNet for Families (MHF) case closes. An Action Notice (FA 450) is sent to Ms. Smith. On 12-23-10, Ms. Smith reapplies for herself and her three children. Ms. Smith does not provide verification of citizenship for herself or her three children. The eligibility specialist (ES) enters "PEND" in the Citizen Document field and leaves the verification field blank on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS. Ms. Smith’s application will pend (case is not approved) 30 days allowing her an additional 30 days to provide citizenship verification. Ms. Smith fails to provide verification of citizenship and therefore, her application rejects.
Whenever possible obtain a copy of the I-94 or other United States Citizenship and Immigration Services (USCIS) document for all aliens in the household for whom assistance is requested. If the alien does provide the requested documentation, verify the documentation with the USCIS using the Systematic Alien Verification for Entitlements (SAVE) System.
If an applicant presents an expired USCIS document or is unable to present any documentation of his or her immigration status, but the alien registration number is known, accept the applicant's statement use the USCIS SAVE System to verify their status. If the alien registration number is unknown, refer the person to the local USCIS District Office to obtain evidence of status. Refer to 1805.020.15 Documentation and Verification of Alien or Immigrant Status of the Family Healthcare Manual - MAGI for additional information on acceptable forms of verification of alien or citizenship status.
Contact the USCIS at any time if there is any reason to question the authenticity of a document presented or the information on the document is insufficient to determine whether the alien status requirement is met.
Citizenship documentation requirements for Temporary Assistance were not changed by the Deficit Reduction Act (DRA) of 2005. Temporary Assistance benefits may only be granted to either a citizen or a qualified alien as defined in Title 8, Section 1641 of the United States Code, and certain qualified aliens are ineligible for five (5) years from their date of entry. Refer to 0205.040.00 Citizenship and Immigrant Status for additional guidance. Citizenship and alien status are declared on the application. No further actions are required to verify citizenship status for self-declared citizens applying for Temporary Assistance.
In determining need, it is necessary to arrive at the most accurate projection possible of the assistance group's gross monthly income. Client's statements must be independently verified, using the best information available. Verification and case recording must support, to the greatest extent possible, that all sources of income have been identified, and that the budgeted amounts are accurate.
Note: Although application interviews are not required for Medicaid/MC+ cases, it may be necessary to contact the client to clarify information obtained from the verification provided.
Obtaining verification of earned income is required for all eligibility determinations. Documentary evidence (examples: wage stubs, written statement from employer, The Work Number) must be obtained for any earned income source claimed by the client. The verification obtained must represent the best information available that can be used to predict future earned income.
IMES information must be checked for all assistance group members age 18 or older to help ensure that the applicant has provided full and complete information. However, IMES information is not considered verification of earned income.
Note: Although application interviews are not required for Medicaid/MC+ cases, it may be necessary to contact the client to clarify information obtained from the verification provided.
Obtaining verification of unearned income is required for all eligibility determinations. The verification obtained must represent the best information available that can be used to project future unearned income. Verification of unearned income received during the past 30 days must be obtained if available. Verification is to be obtained through the system whenever possible. Examples:
For other unearned income not in the system, verification must be obtained from the appropriate source. Examples:
Note: Bank statements are not to be used as verification of unearned income such as OASDI, SSI, etc., even if the income is being directly deposited into the bank account. The amount deposited into the bank is the net amount (after Medicare deductions, for example), and therefore cannot provide accurate verification of gross income.
Need determination is based on a projection of gross monthly income the assistance group is expected to receive from the date of application or reinvestigation forward. If income is received other than monthly, convert it to a monthly amount.
To arrive at a monthly amount:
Verification and recording must clearly show how the projected income was determined.
Earned income is subject to many variables. Consider all factors which could affect the income projection. To project earned income:
Based on the above evaluation of wage information, determine how best to use the information to project monthly income. In all circumstances, recording must clearly support the worker's decision.
It is not necessary to verify child care expenses unless the amount claimed is excessive or there is reason to question the applicant's statement.
Resources only need to be verified for programs with an available resource, real and personal property, or total property limit. Resources include: cash and securities, real property, CSV of life insurance and pre-need burial plans, and personal property. The type of verification required depends on the type of resource.
Verification of the amounts in savings and checking accounts and time deposits on deposit in banks or similar institutions is required. It may also be necessary to verify the closing of previously known accounts. Such verification can be secured from current (no more than 30 days old) bank statements or other papers which the claimant has or can secure. Verification can also be obtained directly from the institution with the claimant's written permission (use form IM-6 or IM-7 to obtain permission).
NOTE: If the financial institution will not provide the information requested to the FSD, requires payment for the response, or requires a company specific form, inform the applicant/participant that they must obtain the information from the institution directly.
Self-attestation of a Direct Express account balance may be accepted if the information provided by the applicant/participant is not questionable. A Direct Express (DE) benefit debit card is used for deposit of federal benefits such as Supplemental Security Income (SSI), Social Security Retirement (OASDI), Railroad Retirement, or Veteran's Administration benefits.
If the self-attestation is close to or exceeds the program resource maximum, the account balance must be verified. Current month's income is excluded from a DE account.
The claimant's statement as to the amount of cash in their home, on their person, or in a safe deposit box can be accepted provided there is no evidence for a contrary opinion.
Refer to Section 1030.010.20 of the December 1973 Eligibility Requirements manual.
NOTE: If the insurance company will not provide the information requested to the FSD, requires payment for the response, or requires a company specific form, inform the applicant/participant that they must obtain the information from the institution directly.
When there is a possibility that the value of personal property will affect eligibility, verify its value.
When there is little probability that the value of personal property, added to the value of other available resources, will affect the claimant's eligibility the claimant's statement is sufficient verification.
Refer to Section 0920.020.25 of the Family Healthcare manual.
Verification that an individual is eligible for certified extended employment at a sheltered workshop must be obtained prior to excluding the income for Medical Assistance. Accept any of the following as verification: